Reporting GuideEU

EU Digital Services Act (DSA) Transparency Reporting

What to publish, how often, and how to build a reporting pipeline that survives audits.

Covers Article 15 (intermediary), Article 24 (platform/search), and Article 42 (VLOP/VLOSE).

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Author

Sorena AI

Published

Feb 21, 2026

Updated

Feb 21, 2026

Sections

Structured answer sets in this page tree.

Primary sources

Cited legal and guidance references.

Publication metadata

Sorena AI

Published Feb 21, 2026

Updated Feb 21, 2026

Overview

DSA transparency reporting should be treated like regulated financial reporting: defined metrics, controlled data sources, QA checks, executive sign-off, and a repeatable cadence. This page explains what each tier must publish and how to build the data model and workflow that makes reporting reliable and defensible.

Section 1

The reporting stack: Article 15 vs Article 24 vs Article 42 (who publishes what)

The DSA uses a layered reporting model that mirrors the layered obligations model.

You must first determine which layer(s) apply to each service you operate.

Article 15: baseline annual transparency report for providers of intermediary services (with micro/small exclusions unless VLOP/VLOSE).
Article 24: additional reporting obligations for online platforms (and AMAR publication obligations for online platforms and online search engines).
Article 42: enhanced transparency reporting obligations for VLOPs/VLOSEs (at least every 6 months) plus publication/transmission of risk, mitigation and audit materials.

Section 2

Article 15 - Annual transparency reports for intermediary services (minimum dataset)

Article 15 requires providers of intermediary services to publish at least once a year a clear, easily comprehensible report on content moderation.

The report must be machine-readable and easily accessible.

Orders from Member State authorities: volumes, type of illegal content, issuing Member State, and median response/action times (Article 15(1)(a)).
Hosting notices: volumes, type of alleged illegal content, notices from trusted flaggers, actions taken and grounds (law vs terms), automation use, and median action time (Article 15(1)(b)).
Own-initiative moderation: meaningful information on moderation performed on your initiative, including automation use, measures affecting availability/visibility, detection methods and restriction types (Article 15(1)(c)).
Complaints and reversals: counts, bases, decisions, median time, and reversal counts (Article 15(1)(d)).
Automation quality: qualitative description, purposes, accuracy/error indicators, safeguards (Article 15(1)(e)).

Section 3

Article 24 - Online platform transparency + AMAR publication (and statement-of-reasons database)

Article 24 adds two high-impact requirements: (1) extra items in transparency reports for online platforms, and (2) publication of average monthly active recipients (AMAR) for online platforms and online search engines every six months.

It also requires online platforms to submit Article 17 statements of reasons for inclusion in a Commission database.

Article 24(1) additions (online platforms): dispute settlement metrics and suspension metrics (Article 23 suspensions).
Article 24(2) AMAR: publish AMAR in the Union by 17 Feb 2023 and at least once every 6 months thereafter (calculated over the past 6 months).
Article 24(3): provide AMAR data and substantiation on request to the DSC of establishment and the Commission (no personal data).
Article 24(5): submit Article 17(1) statements of reasons for inclusion in the Commission's public, machine-readable database; ensure submissions do not contain personal data.
Practical takeaway: your statement-of-reasons pipeline is part of reporting infrastructure.

Section 4

Article 42 - VLOP/VLOSE enhanced reporting (six-month cadence + risk/audit publication)

For VLOPs/VLOSEs, transparency reporting is more frequent (at least every 6 months) and includes publication/transmission of systemic risk and audit materials.

This creates a public accountability loop: risk assessment -> mitigation -> audit -> publication.

Cadence: publish Article 15 reports within the specified window and at least every 6 months (Article 42(1)).
Content: include language breakdown of moderation resources, qualifications, training, support, and linguistic expertise by language; the implementing regulation uses CEFR as the benchmark and sets CEFR-B2 as the minimum threshold for sufficient linguistic expertise.
AMAR by Member State: include recipients per Member State (Article 42(3)).
Publish/transmit: risk assessment report, mitigation measures, audit report, and audit implementation report (Article 42(4)), with confidentiality carve-outs (Article 42(5)).

Section 5

Implementing Regulation (EU) 2024/2835: templates, periods, format, retention, and versioning

The DSA reporting duty is no longer just a high level obligation in Articles 15, 24, and 42. Implementing Regulation (EU) 2024/2835 now defines the reporting templates, the harmonized periods, and the publication mechanics.

If your reporting process still relies on ad hoc PDFs or inconsistent time windows, it is now out of step with the Commission reporting model.

Use the Annex I templates from 1 July 2025 onward for Articles 15, 24, and 42 reports.
Publish each transparency report no later than 2 months after the end of the relevant reporting period.
For the transition year, the second reporting cycle starts no later than 17 February 2025 and runs until 31 December 2025; harmonized periods apply from 1 January 2026.
Publish the completed templates in ODF CSV format, complying with RFC 4180 and UTF-8 encoding.
Keep every published report publicly available for at least 5 years.
If you correct errors or methodology changes, publish an updated version that is clearly labeled, dated, and explained, while keeping earlier versions available.

Section 6

Reporting data model (recommended schema you can implement)

A reporting pipeline is easiest to build when you treat reporting as structured data, not a narrative document.

Use this schema to define authoritative data sources and QA checks.

Metric dictionary: metric name, DSA article reference, definition, source systems, data owners, and validation checks.
Event logs: notice events, action events, restriction events, complaint events, dispute settlement events, suspension events.
Decision metadata: legal vs terms grounds, automated means flags, timestamps, and territorial scope/duration fields for restrictions.
Time-to-action metrics: median times for orders/notices/complaints, with segment breakdowns you can reproduce.
Publication pack: generated report + dataset snapshot + QA report + sign-off + version history.

Section 7

QA and defensibility checklist (what auditors/regulators ask first)

Reporting failures are often data quality failures: missing definitions, inconsistent counting, or inability to reproduce results.

Use this checklist to make reporting defensible.

Reproducibility: can you rerun the report for the same period and get the same results?
Completeness: do all required Article 15/24/42 elements exist (for your tier) and are they clearly labeled?
No personal data in public submissions where prohibited (e.g., statement-of-reasons database submissions).
Automation disclosures are complete and consistent across notifications and report numbers.
Governance: named owner, review cadence, and change management for metric definitions.
Format compliance: publish the report in the Commission template structure and machine-readable ODF CSV format, not as an unstructured narrative only.
Version control: if a report is corrected, keep the original public version, explain the changes, and preserve the full version history for the 5-year retention period.

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Primary sources

References and citations

Commission Implementing Regulation (EU) 2024/2835 - Transparency reporting templates

eur-lex.europa.eu

Referenced sections

Sets the harmonized reporting templates, reporting periods, publication deadlines, CSV format requirements, retention period, and versioning rules.

European Commission - DSA guidance on publishing average monthly active recipients (AMAR)

digital-strategy.ec.europa.eu

Referenced sections

Commission guidance on the requirement to publish user numbers (AMAR) under the DSA.

Regulation (EU) 2022/2065 (Digital Services Act) - Official Journal

eur-lex.europa.eu

Referenced sections

Primary reporting obligations in Articles 15, 24, and 42, including AMAR publication cadence and statement-of-reasons database submission requirements.

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